The financial services industry has spent the past decade debating which ledger technology is the right foundation for real-world asset ownership. The debate is real, but it is downstream of a problem that gets less attention: before you decide where to record ownership, you need to decide how ownership will be described. The identifier scheme, the schema, the representation of beneficial interest, the connection between on-chain records and off-chain legal title. These are standards problems, not technology problems. And they are the ones that actually determine whether institutional ownership data is interoperable, auditable, and compliant.
We are not saying that ledger technology is irrelevant. We are saying that a good ledger running bad data standards produces well-organized bad data, which does not help anyone.
What a Data Standard Actually Does
A data standard for ownership records is a set of agreements about how information is represented. It specifies the identifier types that will be used for instruments and for holders, the schema for an ownership record, the representation of fractional ownership, the relationship between position records and transaction records, and the handling of edge cases like corporate actions, escheatment, and inheritance.
Without a standard, each participant in an ownership chain uses the scheme that was most convenient for that participant. A tokenization platform uses a wallet address as the instrument identifier. A custodian uses a CUSIP. A fund administrator uses an internal code. All three may hold records that relate to the same instrument. None of them are wrong within their own system. But the absence of a common standard means that reconciling across the three systems requires bespoke translation logic for every combination, and that translation logic has to be maintained and updated every time any participant changes its internal scheme.
This is not hypothetical. It is the current state of the RWA ownership data ecosystem, and it is why back-office teams at asset managers spend as much time on data preparation as they do on reconciliation itself.
The ISO 20022 Baseline and Its Gaps for RWA
The closest thing to an accepted data standard for financial ownership records is ISO 20022, the international standard for financial messaging that covers securities, payments, trade finance, and related domains. ISO 20022 provides message schemas for ownership transfers, corporate actions, custody reporting, and reconciliation. It is used by SWIFT, by major custodians, and by a growing number of settlement infrastructure providers.
ISO 20022 is a reasonable starting point for traditional securities. It was not designed for real-world assets in their current forms, and the gaps are significant. The standard's ownership transfer messages assume DTC settlement, which does not apply to directly settled tokenized assets. The identifier fields support ISIN, CUSIP, and a small set of other established identifier types, but not the on-chain identifiers used by tokenization platforms. The beneficial ownership representation model assumes a hierarchical custodial structure that does not map well to direct on-chain ownership.
These gaps are being addressed, but slowly. The ISO 20022 standards process is deliberate, and the working groups that develop new schemas move at a pace that has not kept up with the growth in tokenized asset volumes. In the interim, market participants are filling the gaps with bespoke extensions and proprietary schemas that undermine the interoperability the standard was designed to provide.
Why the Identifier Scheme Is the Most Urgent Problem
Of all the components of an ownership data standard, the identifier scheme is the one with the most immediate operational impact. The reason is simple: every reconciliation process starts with identifier matching. If two records cannot be matched to the same instrument because they use different identifier types, reconciliation cannot proceed regardless of how sophisticated the reconciliation logic is.
For tokenized assets, the identifier problem has an additional dimension. Traditional securities have established identifier types with centralized registries: ISIN for international, CUSIP for US equities and corporate bonds, SEDOL for UK and Irish securities. New tokenized assets are issued on chain with an on-chain address as their identifier, but on-chain addresses are not registered in any centralized reference database. If an asset manager wants to reconcile a tokenized real estate position between its on-chain custodian and its traditional portfolio management system, it needs a mapping between the on-chain address and a traditional identifier. That mapping does not exist in any systematic form.
Some issuers are beginning to obtain ISINs for tokenized securities they issue. This is a meaningful development. But it is voluntary, inconsistent across issuers and jurisdictions, and does not address the large existing inventory of tokenized instruments that have no traditional identifier. The industry needs either a standard for tokenized instrument identification that connects to the existing identifier infrastructure, or a registry that provides the mapping. Neither exists at the required scale yet.
What Your Compliance Team Needs to Know About This Right Now
For compliance teams at asset managers that currently hold or are considering holding tokenized RWA positions, the data standards gap has three direct operational implications.
Regulatory reporting may require manual identifier enrichment. If a regulator asks for a position report that identifies securities by their ISIN or CUSIP, and some of those positions are tokenized assets that do not have traditional identifiers, the compliance team has to maintain a bespoke mapping to produce the report. That mapping must be maintained and kept current as the portfolio changes.
Reconciliation between on-chain and off-chain records will require custom translation logic. The absence of a shared standard means that every integration between a tokenization platform and a traditional custody or portfolio management system requires bespoke translation. Each bespoke integration introduces maintenance burden and is a source of reconciliation errors when either side of the integration changes its internal representation.
Data quality validation is harder without a standard to validate against. Standard-based data quality checks compare records against the constraints defined in the applicable standard: does this identifier match the format required by the standard, does this ownership record include all required fields, is this value within the allowed range for this field type. Without a standard, the validation criteria have to be defined internally, which is both more work and more prone to inconsistency across systems.
What We Built at OpenAssets to Manage the Current Reality
Given that the industry does not yet have comprehensive standards for RWA ownership data, the practical approach is to build the canonical representation internally and invest in translating between your internal canonical form and the various external representations you encounter in practice.
At OpenAssets, our canonical instrument identifier is an internal identifier assigned at ingest, linked to a reference record that carries all known external identifiers for the instrument: ISIN, CUSIP, on-chain address, platform-specific identifiers. Reconciliation within the system uses the canonical identifier. Translation to and from external representations happens at the ingest and export boundaries.
This approach does not solve the industry's standards problem. It manages around it. It also creates an internal reference database that has value beyond reconciliation: when a new identifier type becomes available for an instrument we already hold, we add it to the reference record and it immediately improves the match rate for feeds that use that identifier type. When a standard does eventually emerge that covers tokenized asset identifiers, the translation layer is the only thing that needs to change.
The industry will eventually converge on standards for RWA ownership data. The institutions that invest now in building clean internal data models, with well-maintained identifier mappings and documented translation logic, will adapt to those standards faster and with less disruption than those that continued to manage the identifier problem ad hoc. The infrastructure investment is worth making for its current operational value, independent of the eventual standards outcome.
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